Cookie policy

Cookie Policy

This Cookie Policy describes the types of cookies we use when you interact with Gen II websites or applications. You can always customize your cookie settings when you access them. This Policy applies to all users, regardless of whether you are registered as a user or a visitor.

1. What is a cookie or similar technology?

A cookie is a small text file in alphanumeric format which is placed on the user's terminal (internet browser, computer, mobile device, etc.) by the server of the online service used (the website visited) or by a third-party provider. Such a cookie makes it possible in particular to recognize a visitor when they return to the website, to remember the language that the user had chosen during their previous visit or, in the case of commercial services, the products they had deposited in their basket during a previous shopping session.

Over the years, new technologies (also called "trackers") have appeared to supplement or replace cookies, mainly for their purpose of tracking, profiling, and targeting. These are for example, "fingerprinting" technologies (digital imprint of the terminal), invisible pixels ("web beacons"), "shared objects" (sometimes called "flash cookies") or even all the identifiers generated by operating systems to identify the user. Some might be considered personal data.

Under the General Data Protection Regulation, personal data means any information relating to an identified or identifiable natural person. The individual can be identified directly, or indirectly, in particular by reference to an identifier such as a name, an identification number, or an online identifier.

Insofar as the use of these similar technologies requires the filing or reading of information on the user's terminal, the same regime as for "classic" cookies is applicable to them. For the purposes of this policy, the term "cookies" will be used and will encompass both "classic" cookies and similar technologies.

2. What cookies does Gen II use and for what purpose?

The cookies placed on your terminal may differ depending on the use you make of our website or applications. To view a list of the cookies at a given point in time, please visit your browser settings. For more information about the categories of cookies of each of our websites or to manage preferences, please click on the cookies settings button available at all times on our cookie banner.

Strictly necessary cookies

Certain cookies are strictly necessary as our website will not be able to function without them. They cannot be switched off and are set in response to actions made by you, for example your privacy preferences or when filling in forms, to provide functions across the pages, to enable the website not to show the message more than once to a user, or store cookie consent preferences.

ProviderPrivacy PolicyTurtl Ltd.https://turtl.co/about/legal/privacy-policy/Datadog, Inc.https://www.datadoghq.com/legal/privacy/

Functional cookies

These cookies enable the website to provide enhanced functionality and personalization. For example, they can be used to identify a user across sessions and to remember preferences, track browsing sessions. They may be set by us (first party) or by external providers (third party) whose services we have added to our pages. If you do not allow these cookies, kindly note that some or all of these services may not function properly.

ProviderPrivacy PolicyVimeo, Inc.https://vimeo.com/legal/privacy/policyCloudflare, Inc.https://www.cloudflare.com/privacypolicy/

Performance cookies

Our website uses analytics features that may set cookies with the aim of generating reports on our website visitors and how they interact with our pages (on an anonymized basis). The information collected may show, for example, where in the world the visitor traffic comes from and whether we are appealing to our intended audience, hence allowing us to improve our performance and serve you better via our website, which pages are the most visited, to allow us to understand what we can improve, to track visits across websites, to link visitor to the recipient of an email. All information these cookies collect is aggregated and therefore anonymous.

ProviderPrivacy PolicyHotjar Ltd.https://www.hotjar.com/legal/policies/privacy/

Advertising cookies

Some cookies are used to deliver the most relevant and targeted content to specific audiences. They are specifically designed to gather information from you on your device to display advertisement based on topics that interest you. Additionally, another purpose of these cookies is to build user profiles from visitors to the website in order to gather statistics on the website performance. We use advertising cookies to run our marketing and advertising campaigns on the internet and social media.

3. Categories of Personal Data Collected

Depending on the type of cookies that are installed, we may or may not collect information that is able to identify you as an individual (personal data).

Strictly necessary cookies: We do not collect any of your personal data. We may collect anonymous data relating to internet usage information such as records of your use of our website, including your public IP address, details of your device and location region which cannot identify you as an individual.

Functional cookies: Functional cookies will not be installed unless you have explicitly consented. Such cookies will collect information on your session ID, the login status, language and currency selected, details of your device and location region.

Performance cookies: Performance cookies will not be installed unless you have explicitly consented. Such cookies will collect information on number of users visiting our website, number of sessions, duration of sessions, page views per minute, top active pages, active users, average session duration, bounce rate, new users count, number of sessions per user, page views, pages per session, new or returning visitors, demographics such as language preferences, user's country and user's city, browser, operating system, mobile device operating system, mobile device screen resolution, source of traffic (direct, paid search, organic search, referral or other), user retention, users by time of the day, Client-ID, date last seen, device category, device platforms, acquisition date, channels, related campaigns to the user, age, gender, interests, and social network referrals.

Advertising cookies: They will not be installed on your browser unless you have explicitly consented. Such cookies will collect information regarding your clickstream data (a record of the websites you have visited), search data (search terms you have used, browsing habits), profile data (information you have provided regarding your age, education, interests), on-site activity (such as pages you like, ads you click, device and location settings), demographics and interest reports, user metrics, and traffic data.

To find out more about personal data collected by third parties, please visit the pages indicated in the tables above.

4. How long will cookies remain on your device?

The retention period of a cookie depends on whether it is a session or persistent cookie:

• Session cookies last only for the duration of your visit and allow us to identify that the same person is moving from page to page, without identifying you.
• Persistent cookies last beyond your session and their retention period depends on their specific functionality.

5. Do we transfer cookie data to third countries?

Our website is hosted in the USA and administered by our Marketing and Communications team as well as an external provider in the USA. Therefore, in order for you to be able to use the website, information collected via strictly necessary cookies will be transferred to the USA; however, such information is not able to personally identify you.

Information collected via functional, performance or advertising cookies may be shared with the third party installing the related cookie and such sharing may entail an international data transfer to a country outside of the European Economic Area, potentially not providing an adequate level of personal data protection. We may only share and transfer your personal data to the extent you have provided your active consent via our cookie banner.

6. Who has access to the data collected?

For the purposes of personal data collected on our website through the use of cookies, we act as a data controller. Our marketing agency, Neubrand LLC, has access to the data collected for the purpose of technical website administration and acts as a data processor. We have entered into confidentiality and data processing agreements with our partner to ensure compliance with high levels of data protection and security standards.

The data collected by third parties — including Google LLC, Vimeo Inc., Turtl Ltd., Datadog Inc., CloudFlare Inc., LinkedIn Co., Hotjar Ltd., Meta Platforms Inc., StackAdapt Inc., and Hubspot Inc. — may contain personal data to the extent you have consented to such sharing. In this case, the relevant third party may act as an independent data controller.

7. Special notice to California residents

This section supplements the information provided and applies solely to visitors, users and other individuals who reside in the U.S. State of California. Gen II does not sell your personally identifiable information collected via cookies. It is possible that we share such information with the third parties listed in this Cookie Policy, however, this will only take place upon your explicit consent via your settings of the cookie banner. If you wish to opt out of any kind of sharing of your personally identifiable information, you may at all times click on the "Do not sell" button on our cookie banner and save your preferences.

8. How can you manage cookies?

You can manage cookies in different ways. Where cookies are not strictly necessary for our website to function, we will seek your consent when you first visit the website. Consent can be provided or withdrawn at any time by clicking on the icon available at the bottom of this page. You may also change your browser settings to manage your cookies. Most web browsers provide a way to find out which cookies are used by a website from its developer tools.

Please note: Removing or disabling cookies may have an impact on your user experience and parts of this website may no longer be fully functional.

9. Your rights and how to exercise them

This Cookie Policy is meant to be read together with our Privacy Policy, which is always available on our website. Please refer to our Privacy Policy to see what your rights relating to the protection of your personal data are and how you can exercise them.

10. Changes to this Cookie Policy

We may modify or amend this Cookie Policy from time to time at our discretion. When we do, we will amend the revision date at the top of this page, and such modified or amended Cookie Policy shall be effective as of that revision date. We encourage you to periodically review this Cookie Policy in order to have the latest information about the cookies we use. You also have the possibility to update your cookie preferences at any time directly on our website.